Policy responses and statements

Name of organisation:

Food Standards Agency

Name of policy document:

Labelling: Competitiveness, Consumer Information and Better Regulation for the EU

Deadline for response:

5 May 2006

Background: The Food Standards Agency is seeking views and comments on the European Commission’s consultation document on labelling.

The key points in this consultation are:

• The rationale for labelling legislation

• Food Labelling
  The future scope and structure of food labelling legislation
  Alcoholic drinks
  Nutrition labelling
  Country of origin
  Health warning on alcoholic drinks

• Labelling of non-food consumer products

The attached paper ‘Labelling: Competitiveness, Consumer Information and Better Regulation for the EU’ is a consultative document from the European Commission. It forms part of the EU review of labelling. This document explores the broad approach to labelling of both food and non-food products. It also addresses particular labelling issues such as country of origin labelling and the labelling of alcoholic drinks. The Commission will take into account the outcome of its consultation in drafting proposals for legislation, which are expected, along with an impact assessment, in 2007.

The European Commission’s paper covers areas of policy outside the Food Standards Agency’s remit. These include health warnings on alcoholic drinks, welfare labelling, labelling of non food products, some origin labelling provisions and labelling of some types of alcoholic drinks. The Department of Health, the Department of Trade and Industry, and the Department for Environment, Food and Rural Affairs have agreed that the Agency should co-ordinate the public consultation on this document and that they will consider any responses received that relate to their policy areas before agreeing the Government response. Responses on all these points were therefore invited by the Agency.

COMMENTS ON
FOOD STANDARDS AGENCY
LABELLING: COMPETITIVENESS,
CONSUMER INFORMATION AND
BETTER REGULATION FOR THE EU

The Royal College of Physicians of Edinburgh welcomes the opportunity to comment on the EU proposals for food and drink labelling and would make the following observations:

1. Rationale for labelling legislation

    We favour the introduction of legislation, especially in view of the increasing availability and complexity of processed foods.  We agree with the Commission’s overall approach (Q.1).

   There should be rather firmer prescription to provide greater consistency and a ‘level playing field’ for producers (Q.4).

   The experience of self-regulation in various industries is not conducive to optimism and self-regulation is therefore not favoured.  Co-regulation would require tight partnership agreements (Q.6).

   We would favour the ‘framework’ approach (Q.7).

2. Food Labelling

   We favour a directive approach (Q.8) and feel that there is scope to distinguish two types of information –

   “must be provided” (eg label on product)

   “must be available” (eg address on label/counter/point of sale notices etc) (Q.10)

   Latitude between states should be minimal in view of both free trade and population mobility (Q.12).  Yes – requirements should be fulfilled (Q.13).  However, legislation, while prescriptive, must take account of consultation with producers, consumers, nutritionists and others (Q.14).

3. Alcoholic Drinks

   As with all these proposals, the evidence base is thin.

   We favour listing contents (ingredients) on beverages, even if they mean little to the average drinker ‘on the Clapham omnibus’. All additives should be included and it does not seem logical to put a limit on the strength.  Alco-pops and similar should certainly be included. (Q.17 and Q.18.).

4. Nutrition Labelling

   Nutrition labelling should be mandatory and the Food Standards Agency’s “traffic lights”/MLT is a good example of simple, direct information (Q.19). 

   The MLT four categories would seem a reasonable limit to aim at.  Enrichers, such as folate, should also be indicated (Q.20 and Q.21).

   Nutrition information should include a more relevant message eg “milligrammes/100 cals” or “% calories from fat” rather than simply compositional labelling in milligrammes/100 which requires a PhD in nutrition to work out its significance (Q.22).

   Guideline Daily Amounts might also be considered as a possibility but have the disadvantage of assuming a regular daily diet (which few of us stick to!).  The MLT system might be recommended (Q.23 and Q.24). 

   Dual labelling seems a sensible compromise (Q.26).

   We agree that small packages mean tiny type size requiring a microscope to decipher but cannot see an alternative.  Any presentational issues would be difficult to legislate for but ‘best practice’ could be recommended based NOT simply on industry development alone but in consultation with consumer organisations, nutritionists, health organisations etc (Q.27, Q.28 and Q.29).

5. Country of Origin

   We favour option 3 to prevent misleading (Q.30).

   Some might be interested in ‘food miles’ and their environmental implication (ie CO2 emissions).  Others may wish to be selective on which country’s products they might wish to support (Q.31).

6. Health Warnings on Alcoholic Drinks

   While the College recognises the scant nature of evidence for the effectiveness of health messages (as with smoking), nevertheless, we strongly favour the introduction of mandatory warnings.  It should not be voluntary for the industry and the industry alone should not dictate the message, but should agree with government.  We would not, as before, be sanguine about the industry giving an adequate message.  “Drink Responsibly” (to be seen on one well known brand of lager), for example, is unlikely to carry much of a ‘health punch’ (Q.32 and Q.33).

   Opinion in the informed medical field is divided on the subject of units (Q.35).  Many feel that to display the unit content helps people to monitor their alcohol consumption, but some fear that it encourages the excessive drinker to seek out the ‘best’.  Overall, we favour labelling unit content (and ABV strength as in Britain already) but this is probably best achieved at national level with clear EU guidelines.  The health message will vary from country to country but will require back-up campaigns on responsible drinking (even given the acceptance that most health education changes attitudes but not behaviour) (Q.35, Q.36 and Q.37).

   The process of developing health warnings should be determined on a national level by an expert task group that is not dominated by the beverage industry (Q.38).

Copies of this response are available from:

Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.

Tel: 0131 225 7324    ext 608
Fax: 0131 220 3939

[5 May 2006]